Whistleblower protection policy

Objective and scope

Biome Grow Corporation and its subsidiaries are committed to the highest standards of transparency, honesty and accountability. We pride ourselves on being good corporate citizens. We are committed to complying with all regulatory and legal requirements, to our Code of Business Conduct and Ethics (“Code”) which demands the highest standards of business practices and ethics by Biome Grow’s executive leadership, directors, officers, suppliers and employees.

As a result, Biome Grow and its subsidiaries need to know about any and all dishonest, fraudulent or unacceptable behavior, conduct or practices committed by the BIOME’s employees or consultants, which, if disclosed, could reasonably be expected to raise concerns regarding the integrity and ethics of BIOME .

BIOME ensures that employees and suppliers and third parties will feel safe and treated fairly when reporting and disclosing on any concerns, and throughout the investigative process.

In accordance with BIOME’s commitment set out above, this Whistle Blowing Policy (the “Policy”) is meant to provide a formal yet simple procedure to facilitate the receipt, retention, review and resolution of complaints, denunciations, warnings, given in any form by any BIOME employee or consultant or any other person, regarding illegal activities or Wrong Doings.

The Company has a whistleblower process which demands transparency and accountability.


Background and whistleblowing procedure

Employees or consultants to the Corporation, are often the first to realize that there may be something seriously wrong within a Corporation and may choose not to express or report their concerns because they feel that speaking up would be disloyal to their colleagues or the Corporation or may even feel that reporting concerns would jeopardize their employment with the Corporation.  Even when an employee or consultant does raise or report any suspicions, colleagues or superiors of such employee may decide to ignore his or her concerns so raised rather than address same or report through higher channels what might ultimately turn out to be just a suspicion of fraudulent or wrongful practices.

The Corporation expects employees of, and consultants to, the Corporation, who have reasonable grounds for believing that there is occurring, or has occurred, illegal or unethical practices or Wrong Doing within the Corporation must be encouraged to come forward and voice those concerns responsibly.

BIOME’s Whistleblower Policy is intended to encourage and enable employees, consultants or third parties to voice their concerns regarding any illegal activity or Wrong Doing within the Corporation rather than ignoring them or, ultimately, feeling compelled to deal with the matter outside of the Corporation due to a lack of the availability of the mechanism provided hereunder.

Any employee or consultant who finds their concerns not satisfactorily addressed by their immediate supervisor (or higher-ranking persons) or the Corporation, or who feels that the seriousness and sensitivity of the issues or people involved require that the reporting of illegal activities or Wrong Doing should neither be addressed to the attention of his immediate supervisor, nor follow the normal corporate reporting channels, but must contact the Chair of the Board of Directors of the Corporation.



Accordingly, it is the Company policy to ensure that when an employee, consultant or third-party has reasonable grounds to believe that illegal activities or Wrong Doing has taken place.


Safeguards against retaliation, harassment or victimization

BIOME understands and acknowledges that one’s decision to report Wrong Doing can be a difficult one to make. Those who raise serious concerns should have nothing to fear. Therefore, the Corporation shall not tolerate any retaliation, harassment or victimization (including informal pressures) and shall take appropriate action to protect employees, consultants or third parties who raise any concerns under this Policy in good faith (a “Concerned Person”).

  1. the Employee discloses this information through a safe and clearly defined process;
  2. the matter will be reviewed and, if warranted, investigated by General Counsel;
  3. the Employee will be protected from harassment, victimization and/or retaliation



All expressions of concerns or reports on Wrong Doings within the Corporation, filed with the Chair of the Board of Directors pursuant to this Policy, will proceed internally on a confidential basis and confidentiality will be maintained to the greatest extent possible.


Anonymous allegations

Expressions of serious concerns or reports on Wrong Doing within the Corporation filed with the Chair of the Board of Directors on an anonymous basis will also be treated appropriately.



The Chair of the Board of Directors in the event of Wrong Doing and if the Event is of a “non-financial” nature, the independent members of the Board (or a Committee of independent directors so designated by the Board), shall determine the steps and procedures to be taken to address the concern appropriately and whether an investigation is appropriate and, if so, what form such investigation should take as well as other parameters (for example whether external investigators should be employed, the timing of such investigation and other such matters as are deemed appropriate in the circumstances).

Except, of course in the case of anonymous allegations, the Concerned Person will be informed of the outcome of any investigation and/or any treatment of his or her claim or notice.